Compliance Monitor (08/28/2025)
Your source for federal updates
August 2025 Compliance Activity
| CMS Hospice Payment Update Rule (Final) – Annual FY issuance – Includes final annual payment update and quality program information. – Other regulations or changes to standing regulations outcome with effective dates (as applicable). | Usually posted in late early August Annual payment rate update begins October 1st Will first appear on the Federal Register Public Inspection Desk https://www.federalregister.gov/pu blic-inspection/current Will move over to the Federal Register within 7 days of initial posting https://www.federalregister.gov/do cuments/current | |
| Medicare Care Compare Refresh Hospice quality scores are publicly reported on the Care Compare website and updated on a quarterly basis. CAHPS star ratings are updated in this quarterly refresh | August Medicare Care Compare https://www.medicare.gov/care- compare/ Information about hospice public reporting https://www.cms.gov/medicare/qu ality/hospice/public-reporting- background-and-announcements | |
| CY 2026 Home Health Payment Update Rule comment due Correction: Comments to CMS due Sep 2, 2025 | Comments are due to CMS on Sep 2, 2025. Instructions for submitting comments appear in the beginning of the rule. | |
| September Compliance Sneak Peek | ||
| Telehealth extension Extension expires Sep 30, 2025 | – Removing geographic requirements and expanding originating sites for telehealth services (42 USC § 1395m(m)); Telehealth services can be delivered to any location in the U.S., including the home of an individual. – Extending the use of telehealth to conduct face-to-face encounters prior to recertification of eligibility for hospice care (42 USC § 1395f(a)(7)(D)(i)(II)); Telehealth encounters prior to recertification of eligibility for hospice care are covered and reimbursable. https://www.congress.gov/bill/119th-congress/house-bill/1968/text?s=2&r=1&q=%7B%22search%22%3A%22telehealth%22%7D#toc-H1605045683F94C959D531FAF6124375C | |
Top Items
What to Expect with the HOPE Assessment Submission and Reporting Launch in iQIES
On October 1, 2025, the Centers for Medicare & Medicaid Services (CMS) will launch the Internet Quality Improvement and Evaluation System (iQIES) functionality for Hospice Outcomes and Patient Evaluation (HOPE) assessment submission and reports. Below is important information about this transition to iQIES. Your hospice organization must register in iQIES by September 10, 2025, to receive access.
Provider Security Officials (PSOs) Need to Register for an iQIES Account
Please note that failure to obtain access to iQIES prior to October 1, 2025, will impact your ability to submit HOPE records once the launch is complete. At this time, we are registering PSOs. For information and instructions to register for an PSO iQIES account, please visit: https://qtso.cms.gov/news-and-updates/iqies-hope-assessment-submission-and-reporting-launch-and-provider-security.
Additional information will be provided when general onboarding begins.
OASIS-E2 Update
Now Available! The draft OASIS-E2 Instruments and OASIS-E2 Change Table are now available in the Downloads section of the CMS OASIS Data Sets webpage at https://www.cms.gov/medicare/quality/home-health/oasis-data-sets
OASIS-E2 Paperwork Reduction Act
The OASIS-E2 Paperwork Reduction Act (PRA) package is available for public review on the CMS PRA Listing webpage as CMS Form Number CMS-10545 | CMS
The OASIS-E2 PRA package was posted with the Home Health Calendar Year 2026 National Proposed Rule (NPRM), which is located here: Federal Register :: Medicare and Medicaid Programs; Calendar Year 2026 Home Health Prospective Payment System (HH PPS) Rate Update; Requirements for the HH Quality Reporting Program and the HH Value-Based Purchasing Expanded Model; Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program Updates; DMEPOS Accreditation Requirements; Provider Enrollment; and Other Medicare and Medicaid Policies
Interested parties may comment on changes proposed for OASIS-E2 via the NPRM public comment process. The public comment period ends 08/29/2025.
HHS Drives Reform to Restore Patient-Centered Care, Announces Request for Nominations of Members to Serve on Federal Healthcare Advisory Committee
The U.S. Department of Health and Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) are establishing the Healthcare Advisory Committee—a group of experts charged with delivering strategic recommendations directly to HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Dr. Mehmet Oz to improve how care is financed and delivered across Medicare, Medicaid and the Children’s Health Insurance Program (CHIP), and the Health Insurance Marketplace.
Nominations must be submitted within 30 days of the publication date in the Federal Register and members will be selected later this year. For more information or to submit nominations, visit the Federal Register Notice at: https://www.federalregister.gov/d/2025-16136.
Hospice/Palliative Care Provider Updates
Hospice Preview Reports for the November 2025 Refresh – NOW AVAILABLE IN QIES
Providers can now access the latest Provider Preview Reports via the Certification and Survey Provider Enhanced Reports (CASPER) application. These reports contain provider performance scores for quality measures, which will be published on the compare tool on Medicare.gov and the Provider Data Catalog (PDC) during the November 2025 refresh.
In the Provider Preview Reports, HIS measure scores are based on HIS data submitted by hospices from Quarter 1, 2024 through Quarter 4, 2024. CAHPS measure scores are based on CAHPS data submitted from Quarter 1, 2023 through Quarter 4, 2024. CAHPS Star Ratings are calculated based on data from Quarter 4, 2022 through Quarter 3, 2024. The claims-based measures reflect claims data collected from Quarter 1, 2023 through Quarter 4, 2024.
Once released in CASPER, providers will have 30 days during which to review their quality measure results. The preview period for the latest Provider Preview Report lasts from August 20, 2025 to September 19, 2025. Although the actual “preview period” is 30 days, the reports will continue to be available for another 30 days, or a total of 60 days. CMS encourages providers to download and save their Hospice Provider Preview Reports for future reference, as they will no longer be available in CASPER after this 60-day period.
Learn more about the Provider Preview Report (HIS and Claims-based measures) here and about the CAHPS Preview Report here. Hospice QRP Key Dates for Providers can be found here. The 3rd Edition HQRP Public Reporting Tip Sheet is available here
HQRP Public Reporting Quarterly Refresh – August 2025
The August 2025 quarterly refresh for the Hospice Quality Reporting Program is now available on the Compare tool on Medicare.gov.
In this refresh, HIS measure scores are based on HIS data submitted by hospices from Quarter 4, 2023 through Quarter 3, 2024. CAHPS measure scores are based on CAHPS data submitted from Quarter 4, 2022 through Quarter 3, 2024. CAHPS Star Ratings are calculated based on data from Quarter 4, 2022 through Quarter 3, 2024. The claims-based measures reflect claims data collected from Quarter 1, 2022 through Quarter 4, 2023.
For additional information, please see the FY2025 Hospice Wage Index Final Rule at https://www.cms.gov/Center/Provider-Type/Hospice-Center.
Home Health Provider Updates
Preview CY 2025 Annual Performance Reports (APRs) are Available in iQIES
The Preview CY 2025 Annual Performance Reports (CY 2025 APRs) for the expanded HHVBP Model have been published in the Internet Quality Improvement and Evaluation System (iQIES).
The CY 2025 APRs provide the HHA’s Annual Payment Percentage (APP) based on performance in CY 2024, the performance year, which will be applied to Medicare Fee-for-Service (FFS) claims with through dates in the payment year, CY 2026. In addition, the CY 2025 APRs provide information related to HHA performance on key metrics that feed into the HHA’s APP, including performance measure scores, Improvement Points, Achievement Points, Care Points, and the Total Performance Score (TPS).
An HHA receives a CY 2025 APR if the HHA:
- Was Medicare-certified prior to January 1, 2023, and
- Had sufficient data for at least five quality measures to calculate a TPS and APP.
Exhibit 1: CY 2025 APR quality measure performance scores time periods for each measure category
| Measure Category | Time Period | Minimum Threshold |
| OASIS-based | January 1 – December 31, 2024 | 20 home health quality episodes |
| Claims-based | January 1 – December 31, 2024 | 20 home health stays |
| HHCAHPS Survey-based | January 1 – December 31, 2024 | 40 completed surveys |
Note: APRs are only available to HHAs through iQIES.
Below is a list of the calendar years that are relevant to the “CY 2025 APR”, namely the baseline year, performance year, publication year, and payment year.
- The baseline year is CY 2022 and is used to calculate quality measure-specific achievement thresholds and benchmarks. CY 2022 and CY 2023 are used to calculate improvement thresholds depending on an HHA’s initial Medicare certification date and availability of sufficient data in the baseline years.
- CY 2024 is the performance year, and HHA performance in this calendar year is measured against 12 quality measures relative to performance of HHAs in each cohort.
- The publication year of the “CY 2025 APR” is CY 2025.
- CY 2026 is the payment year. That means that the HHA’s APP ranging from minus 5% to plus 5% is applied to Medicare Fee-for-Service (FFS) claims with through dates in CY 2026.
Accessing IPRs
APRs are available via iQIES in the “HHA Provider Preview Reports” folder, by the CMS Certification number (CCN) assigned to the HHA. If your organization has more than one (1) CCN, then a report will be available for each CCN. Only iQIES users authorized to view an HHA’s reports can access expanded HHVBP Model reports. For assistance with downloading your HHA’s APR, please contact the iQIES Service Center at 1-800-339-9313, Monday through Friday, 8:00 AM-8:00 PM ET, or by email (iqies@cms.hhs.gov). To create a ticket online or track an existing ticket, please go to CCSQ Support Central.
- Log into iQIES at https://iqies.cms.gov/.
- Select the My Reports option from the Reports menu.
- From the My Reports page, select the HHA Provider Preview Reports folder. The folders and reports on the My Reports page are listed in alphabetical order. Thus, users may need to utilize the “page forward” functionality at the bottom of the webpage to advance to the page where the HHA Provider Preview Reports folder is located. Alternatively, users may change the default number of rows that display on the webpage from 10 to a larger number to view the larger list of folders. Note: Files in the HHA Provider Preview Reports folder are listed in descending order (i.e., in the order of the newest reports to the oldest).
- Select the HHVBP report file, and the contents of the file will display.
Instructions on how to access the APRs are also available on the Expanded HHVBP Model webpage, under “Model Reports.”
The Appeals Process
There are three (3) versions of the APRs: a Preview APR, a Preliminary APR, and a Final APR.
- Once the “Preview APRs” are published, HHAs have 15 calendar days to submit a recalculation request if they find evidence of an error in their report.
- The deadline for submitting a recalculation request for the CY 2025 APRs is September 5, 2025. Please note, recalculation requests do not apply to errors in data submission since submission requirements for the expanded Model align with current Code of Federal Regulations (CFRs).
- Once the “Preliminary APRs” are published on October 2, 2025, HHAs have 15 calendar days to submit a reconsideration request if they submitted a recalculation request and are not in agreement with the recalculation request decision.
- The deadline for submitting a reconsideration request for the CY 2025 APRs is October 17, 2025.
- HHAs also have 7 calendar days to submit a request for administrator review if they submitted a reconsideration request and are not in agreement with the reconsideration request decision.
- The deadline for submitting a request for Administrator review for the CY 2025 APRs is November 6, 2025.
- CMS makes the “Final APRs” available after all recalculation requests, reconsideration requests, and requests for Administrator review are processed, and no later than 30 calendar days before the payment adjustment takes effect on January 1, 2026.
HHAs may submit requests for recalculation requests by emailing hhvbp_recalculation_requests@abtglobal.com. Recalculation requests must contain the following information, as cited in the CY 2022 HH PPS final rule (p. 62331) and CFR §484.375:
- The provider’s name, address associated with the services delivered, and CCN.
- The basis for requesting recalculation to include the specific data that the HHA believes is inaccurate or the calculation the HHA believes is incorrect.
- Contact information for a person at the HHA with whom CMS or its agent can communicate about this request, including name, email address, telephone number, and mailing address (must include physical address, not just a post office box).
- A copy of any supporting documentation, not containing PHI or PII, the HHA wishes to submit in electronic form.
Note: When submitting recalculation and reconsideration requests:
- CMS asks HHAs to only include one CCN per request.
- If you are submitting a recalculation request due to a suspected discrepancy between measure values reported in your APR and measure values calculated internally or by your HHA’s vendor, please consider providing a copy of the internal/vendor report used to generate the internal data to assist CMS with investigating your HHA’s request.
- If possible, confirm whether 1) your internal data are risk-adjusted and 2) the data source used to generate your internal measure values (e.g., OASIS data, claims data).
- Please do not include any PHI/PII.
These instructions are also available on the Expanded HHVBP Model webpage, under “Model Reports.”
NOW AVAILABLE: May 2025 Falls with Major Injury Technical Expert Panel (TEP) Summary Report
The Centers for Medicare & Medicaid Services (CMS) convened a Technical Expert Panel (TEP) on May 12 and 14, 2025, to obtain input on potential cross-setting updates to the Falls with Major Injury (FMI) measure.
CMS intends to move forward with updates to the FMI measure based on input received during the TEP. Additional guidance related to updates to the Quality Measures User’s Manual, clinical guidance manuals, technical specifications, and public reporting timelines will be provided at a future date. In the interim, stakeholders are encouraged to review the TEP Summary Report for additional detail on the proposed updates and the rationale discussed by the TEP.
The TEP Summary Report can be found in the Downloads section on the Home Health QRP Quality Measures webpage.
Home Health Prospective Payment System Grouper: October Update
Get the October 2025 release (Version 06.1.25 (ZIP)). See Home Health Prospective Payment System Grouper Software for a summary of changes.
More Information:
- Claims Processing Manual, Chapter 10 (PDF), section 80
All Providers Updates
Seasonal Flu Vaccine Pricing for 2025–2026 Season
Get payment allowances and effective dates for the 2025–2026 season.
More Information:
- Flu Shot webpage: frequency, coverage, billing, codes, and resources
Crushing Fraud Chili Cook-Off Competition
Using explainable AI to identify indicators and solutions to Medicare fraud
The Centers for Medicare & Medicaid (CMS) is excited to announce the Crushing Fraud Chili Cook-Off Competition – a market-based research challenge aimed at harnessing explainable artificial intelligence (AI), specifically machine learning (ML) models, to detect anomalies and trends in Medicare Fee-for-Service (FFS) claims data that can be translated into novel indicators of fraud. This challenge also seeks innovative, scalable technologies that reduce labor-intensive processes while keeping humans meaningfully in the loop to ensure effective oversight and interpretability.
The Chili Cook-Off will unfold in two phases.
Phase 1 – Proposed Technology Development
CMS invites research proposals from all interested parties. After reviewing submissions, 10 teams will be selected as finalists and advance to Phase 2.
Proposal submissions must be tailored to the Medicare FFS claims data that will be provided in Phase 2 via CMS’ Limited Data Sets (LDS).
Phase 2 – Competition
Following a completed and approved Data Use Agreement (DUA), finalists will receive access to the 2022-2024 Standard Analytical Files (SAF) LDS data containing Medicare FFS Hospice, Part B, and DME claims for a random 5% sample of Medicare beneficiaries. Participants will apply their proposed explainable AI/ML techniques to the data and submit a summary of their findings. CMS will select and publicly announce the challenge winner.
CMS launched an oversight initiative on 8/19/2025 to ensure that enrollees in Medicaid and the Children’s Health Insurance Program (CHIP) are U.S. citizens, U.S. nationals, or have a satisfactory immigration status. CMS will begin providing states with monthly enrollment reports identifying individuals whose citizenship or immigration status could not be confirmed through federal databases, including the Department of Homeland Security’s Systematic Alien Verification for Entitlements (SAVE) program.
States are responsible for reviewing cases, verifying the citizenship or immigration status of identified individuals, requesting additional documentation if needed, and taking appropriate actions when necessary, including adjusting coverage or enforcing non-citizen eligibility rules. CMS is sending the first set of reports to states today, with all states receiving a report over the course of a month. We expect states to take quick action and will monitor progress on a monthly basis.
- The rates at which enrollees leave acute care hospitals against medical advice (AMA) have steadily increased since 2006 across most demographics we analyzed and spiked during the COVID-19 public health emergency.
- Enrollees who left AMA were more likely to have poor health outcomes than enrollees discharged to their homes.
- The rates at which enrollees have left AMA appear inversely correlated to the quality of-care ratings of the associated hospitals— the lower the rating, the higher the rates.
- Enrollees eligible for both Medicare and Medicaid (dual enrollees) and enrollees with a mental health diagnosis were more likely to leave AMA than Medicare-only enrollees and enrollees without a mental health diagnosis, respectively.
- This data brief may be beneficial in the development of future guidance to address this growth, which could improve enrollee health outcomes and save taxpayer dollars.
Educational Opportunities
Combating Medicare Parts C & D Fraud, Waste & Abuse — Revised
CMS updated this web-based training course, including:
- Penalties for violating specific laws
- Real-world fraud, waste, and abuse examples
Nursing Home Care Compare Updates: Temporary Pause
CMS recently transitioned to a cloud-based iQIES for nursing home survey and certification data. We’ll temporarily pause Nursing Home Care Compare updates starting July 30 and resume them in October 2025. This temporary pause allows us to ensure publicly reported nursing home quality information is accurate and reliable. For more information, read the Temporary Pause in Nursing Home Care Compare Updates special alert memo.
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